Personal Data Protection Act (PDPA) Policy
Personal Data Protection Act (PDPA) Policy for St. Hilda’s Primary School
St. Hilda’s Primary School recognises the significance of the personal data you entrust to us. We are dedicated to managing, protecting, and processing your data responsibly.
This Data Protection Policy outlines how we collect, use, disclose, safeguard, and handle your personal data in compliance with the Personal Data Protection Act 2012 (PDPA).
1. Introduction to the Personal Data Protection Act 2012
1.1 Definition of Personal Data: "Personal Data" refers to any information, whether accurate or not, that can identify an individual on its own or in conjunction with other information to which the organization has or is likely to have access.
1.2 Examples of Personal Data:
1.2.1 Personal identification information, including name, gender, date of birth, NRIC number, photographs, video recordings, closed circuit television (CCTV) footage, and voice recordings;
1.2.2 Contact information, including postal address, email address, fixed-line telephone numbers and mobile phone numbers;
1.2.3 Personal records and demographic information, including academic history, academic qualifications, medical history, health and sickness reports, employment history and records.
1.3 Collection and Consent: Generally, before collecting any personal data from you, we will inform you of the purposes for which your data may be collected, used, and/or disclosed, and will obtain your consent for these intended purposes.
2. Purposes for Personal Data
2.1 Depending on your relationship with us (e.g., student, parent, alumnus, staff, applicant, vendor, service provider), we may collect, use, and/or disclose your Personal Data for the following purposes:
2.1.1 Assessing suitability for admission or employment, enrolling or employing individuals, providing educational courses and training, including sending course materials, information on timetables and examinations via mail, email, SMS, MMS, fax, or voice calls;
2.1.2 Managing relationships with St. Hilda’s Primary School, including responding to inquiries and sending correspondence, statements, or notices, which may involve disclosing certain Personal Data for delivery purposes;
2.1.3 Conducting due diligence or background checks as required by legal or regulatory obligations or risk management procedures that may be required by law or put in place by St. Hilda’s Primary School, including obtaining references from prior educational institutions and employers;
2.1.4 Processing applications for scholarships, financial aid, and research support, as well as managing related programs, including using Personal Data for development and fundraising activities, and disclosing information to donors, grantors, evaluators, and external organizations for reports, events, surveys, and publicity of St. Hilda’s Primary School’s replated programmes;
2.1.5 Investigating potential fraud, misconduct, or unlawful actions, or omission, and using electronic and video systems to maintain campus security, control access, and investigate suspicious or inappropriate activities;
2.1.6 Responding to information requests from government or public agencies, ministries, statutory boards, or authorised non-government agencies authorised to carry out specific Government services or duties;
2.1.7 Conducting market research and analysis for St. Hilda’s Primary School’s operational strategy and policy planning, including providing data to external parties for program evaluation and sharing information with former academic institutions and partner institutions for joint administered programmes;
2.1.8 Engaging with the community to garner support and resources for St. Hilda’s Primary School, its community and affiliated institutions;
2.1.9 Supporting St. Hilda’s Primary School’s functions, but not restricted to, the teaching and personal and professional development of students, research, and administration of St. Hilda’s Primary School;
2.1.10 Processing and administering applications for overseas exchange programs and related activities, including disclosing information to overseas universities and training organisations;
2.1.11 Processing and conferring awards, medals, scholarships, honors, and other distinctions, and publishing or releasing related information;
2.1.12 Engaging alumni including but not limited to notification on St. Hilda’s Primary School and alumni-related initiatives and activities, invitation to St. Hilda’s Primary School and alumni-related events through notifications, event invitations, updates, surveys, and communications related to alumni initiatives;
2.1.13 Handling applications and enrolment for health, life, travel insurance, service provision, and concession cards, and managing related services;
2.1.14 Processing applications for and administering local and overseas career-related activities, including events, programmes, internships, employment opportunities, and career coaching, and sharing information with companies (whether local or overseas) for recruitment, internship, industrial attachment, job placement and research support;
2.1.15 Facilitating participation in student life and alumni development activities, including social, cultural, athletic, educational events, volunteering and training programmes, student membership and leadership roles in clubs, societies, and orientation/reception activities;
2.1.16 Taking photographs and videos (whether by St. Hilda’s Primary School staff or third-party photographers and/or videographers) during school programmes, events, or seminars organised by St. Hilda’s Primary School or its affiliates for publicity purposes;
2.1.17 Maintaining records, including and not limited to school premises video surveillance, and visitor registration;
2.1.18 Providing updates on St. Hilda’s Primary School events;
2.1.19 With your consent, sending marketing, advertising, and promotional information via mail, email, SMS, MMS, fax, or voice calls;
2.1.20 Any other purposes that St. Hilda’s Primary School may inform you of in writing from time to time, for which St. Hilda’s Primary School will seek your separate consent.
2.2 To facilitate our smooth operations, we may disclose your Personal Data to third-party service providers, agents, or affiliates, either within Singapore or abroad, who process the data on our behalf for the purposes listed above.
3. Specific Issues for the Disclosure of Personal Data to Third Parties
3.1 We are committed to protecting the confidentiality of the Personal Data you provide to us.
3.2 We will not disclose your Personal Data to third parties without first obtaining your express consent permitting us to do so. However, there are certain situations where disclosure may occur without prior consent, including but not limited to the following:
3.2.1 When disclosure is required by applicable laws and regulations;
3.2.2 When disclosure is clearly in your best interests and timely consent cannot be obtained;
3.2.3 When disclosure is necessary to respond to an emergency threatening your life, health, or safety, or that of another individual;
3.2.4 When there are reasonable grounds to believe that the health or safety of yourself or another individual is at serious risk, and timely consent cannot be obtained. We will notify you of such disclosure and its purpose as soon as practicable;
3.2.5 When disclosure is necessary for legal investigations or proceedings;
3.2.6 When Personal Data is disclosed to an officer of a prescribed law enforcement agency, upon presentation of written authorization signed by the head or director of that law enforcement agency or person of a similar rank, certifying that the Personal Data is necessary for the purposes of their functions or duties of the officer; and/or
3.2.7 When disclosure is to a public agency and is necessary for the public interest.
3.3 When Personal Data is disclosed to third parties with your consent, we will ensure that adequate protection measures are in place and will make every effort to ensure these third parties comply with the PDPA and our data protection policies.
4. Request for Access, Correction and/or Withdrawal of Personal Data
4.1 You may request to access or correct the Personal Data we hold, or withdraw your consent for the collection, use, and/or disclosure of your Personal Data at any time by submitting a written request to our PDPA Contact Person (see below).
4.2 When you request access to your Personal Data, we will provide you with the relevant information within a reasonable time frame.
4.3 If you request to correct your Personal Data, we will update the information and notify any organizations to which we disclosed your data within the past year, unless they no longer require the corrected data for legal or business purposes.
4.4 When you withdraw consent, we will process your request within a reasonable time from such a request for withdrawal of consent being made, and will cease to collect, use, or disclose your Personal Data as specified in your request.
4.5 Please note that withdrawing consent may have legal consequences. Depending on the extent of your withdrawal, it could impact our ability to maintain your existing relationship with us.
4.6 We may charge a reasonable fee for handling and processing requests to access or correct your Personal Data. You will be notified in advance of such cost, and we will provide you with a written estimate of the fee we will be charging.
5. Administration and Security Management of Personal Data
5.1
We will make reasonable efforts to ensure that your Personal Data is accurate,
complete, and up to date.
5.2 We will implement reasonable security measures to protect your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage, and/or alteration. However, we cannot be held responsible for unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
5.3 We will also take reasonable efforts and measures to ensure that the Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; (ii) retention is no longer necessary for any other legal or business purposes.
6. Updates on Data Protection Policy
6.1
To ensure the effective management, protection, and processing of your
Personal Data, we will periodically review and update our policies, procedures,
and processes.
6.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. You may request the latest version of the policy at any time.
6.3 We encourage you to periodically check our website, www.shps.moe.edu.sg, for the most current version of our Data Protection Policy to stay informed about our latest practices regarding Personal Data Protection.
7. Complaint Process and Feedback
7.1 If
you have any complaint, grievance, or feedback regarding our handling of
your Personal Data or about our compliance with the PDPA, please feel free
to reach out to us.
7.2 To protect your personal data and security, we will also require you to verify your identity before we can respond to your request.
7.3 You can contact us through the following methods to submit your complaint, grievance, or feedback:
7.3.1 Singapore Telephone Number: 64350211
7.3.2 Email: shps@moe.edu.sg. Attention it to the ‘Data Protection Officer’
7.3.3 School Address: 2 Tampines Avenue 3, Singapore 529706
7.4 We are committed to deal with any complaint, grievance or feedback that you may have efficiently and fairly.